Corrective Action Plans

Finding No. 2022-001 The University verified the internal processes to this report and verified the operating system manual used by the University from the report. After this assessment on May 5, 2021, the University is review and amended the procedure for identifying students who met the graduation requirements. This procedure was done with the purpose of ensuring sent this report in the time required according by the regulations. This procedure is effective from fiscal year 2021 - 2022, as notified in the action plan for last year. As a result of the implementation of this process, the number of students was reduced by fourteen (14), from 16 to 2 compared to last year. This represents a reduction, of fifty-six percent (56%). In addition, to what has been previously explained, training and retraining will continue for all offices and departments that involved in the process established by the University. On the other hand, the University will continue to monitor the process by conducting internal audits to guarantee compliance with regulations in this matter.

Prior Year Finding Number: 2022-001 Fiscal Year in Which the Finding Initially Occurred: 2022 Federal Program, CFDA Number and Name: U.S. Department of Education, Student Financial Assistance Cluster ? CFDA 84.268, Federal Direct Student Loans; CFDA 84.063, Federal Pell Grant Program; CFDA 84.007, Federal Supplemental Educational Opportunity Grants Condition: The University did not accurately report a student status change to the NSLDS in a timely manner. Of the 40 students selected for enrollment reporting testing, the status change for 1 student was not accurately reported as withdrawn within the required 60-day period. Planned Corrective Action: The cause of the error has been found and the University has implemented additional controls to ensure that student graduation status is reported in a timely manner. Contact person responsible for corrective action: Diane Praet, Registrar Anticipated Completion Date: 12/31/2022

The office of the Registrar will work with the academic administration to increase faculty education on the importance of timely reporting on non-attendance, to include a presentation at Faculty Orientation. Additionally, communications to all faculty will be sent at the census period and mid-point of the term, reminding them of the attendance policy and reporting requirements. Lastly, Division Chairs and Vice President of Academic Affairs will be sent a list of non-compliant reporting faculty for follow-up at week 3 and week 9.

Finding No. 2022-001 - Internal Controls over Student Financial Assistance Special Tests and Provisions Condition: During the compliance testing, we noted the following exceptions: ? During the compliance testing of ?Special Tests and Provisions ? Return of Funds? we noted that one (1) student calculation used the incorrect institutional charges in the calculation and one (1) students funds were not sent back to the Department of Education within the required 45 day time frame. ? During the audit of the Federal Student Assistance Cluster we noted one (1) instance where the income tax reported on the Institutional Information Record (ISIR) did not match the information on the student?s income tax transcript. Plan: The Financial Aid Office has revised the worksheet used for Return of Funds calculation to include separate lines for tuition, fees, and books instead of only the aggregate total. The Financial Aid Specialist is training to perform the Return of Funds calculations. Going forward, when the Specialist performs the calculations, the files subsequently will be reviewed by the Director of Institutional Compliance and Research. When the Director of Institutional Compliance and Research reviews the R2T4 files for accuracy, she will also pull up the student?s file in COD to verify the amount has been transmitted. The Director will print the page for the R2T4 binder. This way the Director will quickly be able to see if a file has not been transmitted to COD. The Financial Aid Office staff has been retrained on separating tax information when a student (or parent) filed jointly and is now divorced, which was the case in the noted error. The staff will now leave the percentage to all decimal places in the calculator before multiplying it by the taxes paid. This will remove the chance for error due to rounding. Anticipated Date of Completion: Immediately upon learning of the deficiency. Contact Person Responsible for Corrective Action: Amy Epplin, Director of Institutional Compliance & Research

Management?s Response The UPR concurs with this finding. To address the situation and take corrective actions, a meeting was held at the Vice Presidency for Academic Affairs and Research on March 15, 2023 with registrars of the eleven (11) units of the UPR System. The following actions were proposed as corrective actions: ? Registrars were instructed to attend a Federal Student Aid workshop on March 28, 2023, on Loan Servicing, Enrollment Reporting, and the National Student Loan System. ? Professors will be oriented on the importance of taking and reporting attendance timely. ? All campuses must use the NEXT System (student data platform developed internally) to report partial and total withdrawals, as well as the attendance report. (We noted that the units that are using NEXT System did not have findings). For the five students of RUM and RCM the UPR was unable to provide information from NSLDS; the search on the website displayed ?Search returned 0 students. No matching students records found?. On December 9, 2022 RUM contacted NSLDS Customer Service Center by e-mail. They later received an e-mail informing the case was closed without further explanations. Also, NSLDS issued electronic announcements confirming problems with the implementation of their new website. On the other hand, RUM was able to provide evidence to auditors that they reported the status change of all students to the Clearing House on time. Responsible Person or Office: Executive Vice President for Academic Affairs and Research. Timeline: June 2024

BSMH has implemented enhanced policy and procedures to assist with managing data and enrollment reporting. The procedures include an enhanced review by the Registrar of the student data reports prior to NSLDS submission to ensure no omissions. The contact for this finding is Mark McKellip, Registrar, Mark.McKellip1@mercycollege.edu.

Satisfactory Academic Progress Planned Corrective Action: To receive financial aid students must maintain a cumulative grade point average (GPA) of 2.0 (?C?) or better, or be in a SAP-Probation program to recover their GPA. Pillar College academic standards require a student to have a minimum of a 2.0 cumulative Grade Point Average (GPA) to graduate. Degree seeking students will be evaluated for Satisfactory Academic Progress (SAP) on an annual basis. Pillar College is dedicated to helping students succeed academically and progress to graduation and is therefore committed to identifying students who may be struggling. Satisfactory Academic Progress is measured by three components: 1) The student?s cumulative grade point average (CGPA), 2) The student?s rate of progress toward completion (ROP), and 3) The maximum time frame (MTF) allowed to complete the academic program. (150% for all programs.) All students who receive financial aid at Pillar College are required to meet qualifying Academic standards. The student must maintain Satisfactory Academic Progress (SAP). If a student?s cumulative GPA falls below a 2.0, the student will be placed in Suspension Pending and must appeal to remain in school. Upon review of the appeal, the student will be placed on SAP Probation for the following semester/year and directed to the Academic Resource Center (ARC) for mandatory tutoring sessions through registration into ARC-090 SAP Remediation, a pass/fail course for SAP students. For the LEAD Program, the GPA benchmark is 2.5 to remain in the program. The probationary status permits the student to continue in college while working with the Academic Resource Center (ARC) to address deficiencies and take corrective action for improvement. The student may continue to receive Title IV and State Financial Aid so long as they are adhering to their SAP Remediation Plan. The student must use the SAP Remediation Form while on SAP Probation (available from the ARC). An assessment of current enrolled students? degree progress will occur mid-July. If the SAP standard is not being met, the student will be placed on SAP-Probation. It is possible to continue to receive Financial Aid while on SAP-Probation if the student?s ?Academic Plan? is being followed, and grades are improving. If a student does not adhere to the ?Academic Plan?, they may be moved to SAP-Suspension, and removed from the financial aid program. Aid will also be suspended for the semester if credit hours attempted fall below the credit hour criteria. Pillar College financial aid office, the Academic Resource Center (ARC) and the registrar?s office met to discuss and update the Satisfactory Academic Policy (SAP policy), implementing the changes in the current fiscal year. These changes are reflected in the Pillar College Catalog. Due to upgraded student services systems the process is functioning more effectively and efficiently. As stated before, an assessment of current enrolled students? degree progress will occur mid-July. The registrar, financial aid, and the Academic Resource Center (ARC) will meet together as a team two days after the report is published to discuss the results. Students will be notified individually through phone calls and emails to make an appointment with the Academic Resource Center to create a self-evaluative plan to increase their GPA. The ARC will upload the plan into the student services system and monitor the student?s progress by direct contact with the student. It will be noted in the student services system under the individual student?s account if a student does not respond to the notices, phone calls or emails that are sent. The student will be put on academic hold and will not be able to enroll in the new semester. Person Responsible for Corrective Action Plan: Betzi Schroeder, Financial Aid Office Anticipated Date of Completion: current

Inaccurate and Untimely Returns to Title IV Planned Corrective Action: Pillar College changed the R2T4 policy in the catalog and created an R2T4 form to monitor the process. Our operating system, Anthology, has been upgraded to include automatic triggers. The automated system alerts financial aid, the third-party servicer and the registrar to process and critique the effects of the student?s official and/or unofficial withdrawal. Three specific processes have been created and are combined under ?Withdrawal Process Flow Charts: Official, Unofficial and Non-Returning Student?. After analysis the financial aid office and third-party servicer determine the potentiality of funds to be returned to Title IV in a timely manner. Person Responsible for Corrective Action Plan: Betzi Schroeder, Financial Aid Officer Anticipated Date of Completion: current

Enrollment Reporting to NSLDS Planned Corrective Action: The college will continue to process the semi-monthly NSLDS reporting through the SIS and undertake spot checking 10% of the reported students after each enrollment reporting submission is completed to ensure accurate enrollment reporting. The errors will be fixed, and the type of errors will be tracked to modify the SIS as needed. Person Responsible for Corrective Action Plan: Brian Schroeder, Registrar Anticipated Date of Completion: current

2022-002 Federal Direct Loan Reconciliations Assistance Listing Number: 84.268 Criteria According to 34 CFR 685.300(b)(5), the school must, on a monthly basis, reconcile institutional records with Direct Loan funds received from the Secretary and Direct Loan disbursement records submitted to and accepted by the Secretary; Condition The University did not perform the monthly reconciliations over direct loans. Context We requested a selection of reconciliations out of the 12 required and were informed that only a year-end reconciliation was performed. Cause The reconciliations were not performed due to the University being short-staffed. Effect Direct loan discrepancies may not have been identified and resolved in a timely manner due to the lack of monthly reconciliations. Questioned Cost There were no questioned costs related to this finding. Recommendation We recommend that the University perform direct loan reconciliations monthly to ensure that discrepancies are properly addressed in a timely manner. Planned Corrective Action Existing fiscal staff will now have more bandwidth to help with monthly analysis and accounting close protocols with student services staff. Implementation Date Effective date: 7/1/23 for fiscal year 2024. Responsible Personnel Arlene Cash Interim Vice President for Enrollment Management awcash@ndnu.edu

CORRECTIVE ACTION PLAN Finding 2022-001 Federal Agency Name: U.S. Department of Education Program Name: Student Financial Assistance Cluster ALN: 84.063 and 84.268 Finding Summary: University of Mary Hardin-Baylor (?UMHB?) had three conditions that led to NSLDS reporting discrepancies for five students. Cause 1: A system report used for NSLDS reporting incorrectly included the end of a student?s enrollment term instead of the date of official withdrawal communication. Cause 2: UMHB did not adjust the NSLDS transmittal calendar when UMHB?s academic calendar was modified for an earlier start date. Cause 3: A system report used for NSLDS reporting did not include withdrawal dates for students that had unofficially withdrawn. Responsible Individuals: Trent Bridges, Director of Data Quality & Institutional Analytics Bethany Chapman, Institutional Research Coordinator Corrective Action Plan: Related to Causes 1 and 3: UMHB will review all the coding on system reports used for NSLDS reporting to assess accuracy and completeness of the data based on any changes in business practice and make updates to system reports as necessary. UMHB will update its internal process to document any required special handling of records based on system limitations. UMHB will reassess system report and processes used for NSLDS reporting prior to the beginning of each fall and spring semester. Related to Cause 2: UMHB has adjusted its NSLDS submission schedule according to our new academic calendar with the first of term submission occurring on the census date. UMHB will establish a schedule to include more frequent submissions throughout the term. Additionally, UMHB will run a withdrawal report twice a month and manually adjust enrollment status to ensure these students are reported as withdrawn correctly to NSLDS. Anticipated Completion Date: September 15, 2022

Reference Number 2022-001 Identification: 10.766 United States Department of Agriculture (USDA), Community Facilities Loans and Grants Cluster, Noncompliance Finding/Significant Deficiency, Reporting Compliance Requirement. Corrective Action Plan: The Medical Center will make improvements to its reporting process to include reporting its fidelity bond coverage. The Medical Center will also seek guidance from the USDA as to the fidelity bond coverage limits and who can complete the certification of records on behalf of the Medical Center. We will implement these items as directed by our USDA representative. Anticipated completion date: The Medical Center will implement these improvements immediately which will be effective for its next annual reporting checklist that is due 60 days after calendar year end. Dean Ohmart, CFO Phone: 660-747-2500 E-mail: dohmart@wmmc.com

Sacred Heart University Corrective Action Plan Year ended June 30, 2022 Finding 2022-001: Significant Deficiency and Noncompliance: Special Tests and Provisions ? Enrollment Reporting Corrective Action Planned Sacred Heart University has implemented a corrective action plan which involved collaboration with our enterprise resource provider, Ellucian, the Registrar?s Office, and the Department of Information Technology (IT). Sacred Heart University acknowledges that published program lengths reported on National Student Loan Data System (NSLDS) records did not conform with reporting requirements. The University?s ERP, Ellucian, provided instruction on updating the code for programs with ?years to complete,? which enabled the IT department to identify and correct existing active programs. To prevent future errors the Registrar?s Office can access the mnemonic (screen) to code new program records in ?years to complete.? Sacred Heart University processed and submitted the first two branches, 00 and 81, on 3/24/23, and Clearinghouse took steps to update the records. Sacred Heart University acknowledges incorrectly reporting the Graduated status effective date as the last day of classes instead of the last day of final exams at the NSLDS program level for two students sampled during our FY22 Federal Single audit. The University has amended its procedures to avoid potential errors causing nonconformities. The updated procedures will ensure the utilization of the last day of final exams as the Graduated status effective date at the program level and strengthen the review of the graduate file before submitting it to the Clearinghouse. Sacred Heart University acknowledges incorrectly reporting the student program begin date for one student sampled during our FY22 Federal Single audit. The University reported the student in the incorrect branch, discovered the error upon graduation, and moved the student to the correct branch. As a result of the branch correction, the University reported to the NSLDS the start date of the student?s last trimester instead of the actual program start date. The Registrar?s office, working with the Clearinghouse, is taking steps to correct the branch reporting which will fix the reported program start date for this particular student. The University is amending its procedures to prevent further noncompliance. The Registrar?s office is amending the report used to ensure students are selected and reported in the correct branches. The Registrar is also enhancing the report to include data identifying potential erroneous reporting before enrollment data is reported to the Clearinghouse. Contact Person(s) Responsible for Corrective Action Angela Pitcher, University Registrar Lori Jo McEwan, Senior Systems Analyst Anticipated Completion Date April 25, 2023

Finding 2022-014 Personnel Responsible for Corrective Action: Director of Financial Aid, James Green Anticipated Completion Date: June 2023 Corrective Action Plan: The calendar for 2022 - 2023 academic year has been updated to ensure the correct number of days are used for return of Title IV calculations.

Finding 2022-013 Personnel Responsible for Corrective Action: Director of Financial Aid, James Green Anticipated Completion Date: June 2023 Corrective Action Plan: The Financial Aid staff will ensure systems are setup to prevent the over award of federal financial aid. The financial aid counselor will prepare and award the student. Upon completion, the financial aid counselor will submit the file to the Director of Financial Aid for the second review. The University Financial Aid officers will undergo a series of trainings and certifications through the National Association of Student Financial Aid Administrators to assist with understanding aggregate limits for federal student aid.

Finding 2022-012 Personnel Responsible for Corrective Action: Assistant Comptroller - Brian Huggins Anticipated Completion Date: July 2022 Corrective Action Plan: The University has implemented a process to document all allowable costs prior to funds being draw down that will be prepared by a Senior Accountant, reviewed by the Assistant Comptroller and Comptroller for 2nd review, and sent to the CFO for final review and approval prior to requesting reimbursement/cash drawdowns from the Federal Government. Moreover, the University is implement a quarterly grant review process with the grant Principal Investigator to review grant expense allocations. G5 drawdowns will take the second Monday of each month.

Holy Family University respectfully submits the following corrective action plan for the year ended June 30, 2022. Name and address of independent public accounting firm: Baker Tilly US, LLP 1650 Market Street, Suite 4500 Philadelphia, Pennsylvania 19103 Audit period: June 30, 2022 The findings from the June 30, 2022 schedule of findings and questioned costs are discussed below. Finding 2022-001: Special Tests and Provisions - Gramm-Leach Bliley Act (?GLBA?) 84.268 Federal Direct Loan Program; 84.063 Federal Pell Grant Program, 84.033 Federal Work Study Program, 84.007 Federal Supplemental Education Opportunity Grant; 84.038 Federal Perkins Loan Program Recommendation: The University should perform and document an annual risk assessment to determine the University's specific risks relevant to protecting consumer nonpublic personal information. At a minimum, the University should have at least one risk statement aligned or referenced to each of the three required areas noted in the GLBA law at 16 CFR 314.4 (b). Finally, the University should identify and document at least one safeguard (i.e., control) for each of the risks identified and document in the risk assessment. Each control should be aligned or referenced to the risk(s) to which the safeguard applies. Action Taken: The institution acknowledges and understands the requirements set forth by the Gramm-Leach-Bliley Act (GLBA) and is in the process of selecting a qualified individual for the partner role. Our team is actively developing a timeline to ensure full compliance with GLBA by June 9, 2023. In order to prioritize our efforts, we have identified areas of risk and implemented risk-based priorities to strengthen our network security, including firewalls, email access with Multi-Factor Authentication (MFA), applications, and policies/procedures. As part of our compliance efforts, our team will conduct a risk assessment to address three areas of concern, including 1. employee training and management 2. information systems (including network and software design 3. as well as information processing, storage, transmission, and disposal), and detecting, preventing and responding to attacks, intrusions, or other systems failures. We will document safeguards for identified risks by June 30, 2023. Name(s) of Contact Person(s) Responsible for Corrective Action: Mark Green, Associate Vice President Institutional Effectiveness, IT, and Innovation Anticipated Completion Date: June 9, 2023 If there are any questions regarding this corrective action plan please contact Eric Nelson, Vice President for Finance & Administration, at enelson@holyfamily.edu.

2022-004 Eligibility ? Assistance Listing No. 84.063 Recommendation: We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Policy and Procedures of reporting deadlines and requires has been put into action by the director of financial aid. Name(s) of the contact person(s) responsible for corrective action: Grant Pollard, Director of Financial Aid Planned completion date for corrective action plan: 11/1/2022

2022-009 Eligibility ? Assistance Listing No. 84.268 Recommendation: We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Policy and Procedures of reporting deadlines and requires has been put into action by the director of financial aid. Name(s) of the contact person(s) responsible for corrective action: Grant Pollard, Director of Financial Aid Planned completion date for corrective action plan: 11/1/2022

2022-006 Special Tests and Provisions ? Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The director of financial aid works with the third-party servicer to ensure accurate student programs and program beginning dates reported to NSLDS. The financial aid office cross-references program information within the student information system. Name(s) of the contact person(s) responsible for corrective action: Grant Pollard, Director of Financial Aid Planned completion date for corrective action plan: 11/1/2022

2022-005 Special Tests and Provisions ? Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The director of financial aid works with the third-party servicer to ensure accurate and timely enrollment updates to NSLDS. Name(s) of the contact person(s) responsible for corrective action: Grant Pollard, Director of Financial Aid Planned completion date for corrective action plan: 11/1/2022

2022-003 Eligibility ? Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the College provide additional resources to ensure all compliance requirements are met. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The director of financial aid reviews the funding estimate (award package) put together by the third party servicer and signs/e-signs it to document his review. Name(s) of the contact person(s) responsible for corrective action: Grant Pollard, Director of Financial Aid Planned completion date for corrective action plan: 11/1/2022

Incorrect and Late Returns of Title IV Funds (R2T4) Planned Corrective Action: Executive Director of Financial Aid has reviewed and updated policy and COD system set-up to ensure correct calculations. Executive Director of Financial Aid provided in-house R2T4 training specific to WBU for all staff as well as will ensure all pertinent staff responsible for R2T4 complete R2T4 training provided by FSA and purchased through NASFAA. Audit report is now generated weekly to identify students who have withdrawn and reviewed by appropriate staff to ensure timely R2T4 completions. Executive Director of Financial Aid is working with IT (and others) to integrate BlackBoard course activity data with PowerCampus for most accurate record of course attendance and last date of academically related activity for all students. This implementation is being piloted during Fall 2 session, with plans for full implementation for the Spring 2023 term. WBU has funded a Financial Aid Compliance Specialist position in the Office of Financial Aid. Once filled, this position with be devoted to internal audit and federal/state regulation compliance. Person Responsible for Corrective Action Plan: Christy Miller, Executive Director of Financial Aid Anticipated Date of Completion: January 2023

Concordia University Irvine An Educational Institution of The Luther Church - Missouri Synod Schedule of Findings and Questioned Costs June 30, 2022 Finding 2022-001: Significant Deficiency - Return of Title IV Funds Program: Federal Direct Student Loans Assistance Listing Number: 84.268 Federal Agency: U.S. Department of Education Federal Award Identification Number: P268K223683 Federal Award Year: June 30, 2022 Criteria: 34 CFR 668.22 requires that when a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV grant or loan assistance that the student earned as of the student's withdrawal date in accordance with Federal regulations and return the unearned portion of the grant or loan funds to the Title IV programs as soon as possible but no later than 45 days after the withdrawal date. Condition/Context: In a sample of 15 students that withdrew during the fiscal year, the University did not perform the required return to Title IV calculations for four students who completed less than 49% of the payment period. For one additional student, a Title IV calculation was prepared, however the calculation was incorrect and an incorrect amount was returned. The sample was not a statistically valid sample. Cause: The University incorrectly interpreted the period of enrollment to be the one module and not the entire payment period for the withdrawal exemption for successful completion of 49% or more. The University's interpretation was made in May 2021 and therefore impacts students in the 21-22 award year as well as in the 22-23 award year through March 1, 2023 when the error in interpretation was confirmed. Effect: The University incorrectly calculated students as having completed more than 49% and therefore did not perform R2T4 calculations or return unearned loan funds to the Department. Additionally, some R2T4 calculations were incorrect based on the calculation using only the module not the days in the payment period. Questioned costs: Total questioned costs were $10,819 of Direct Student Loan funds. Recommendation: It is recommended that the University review interpretations, policies and procedures in place for withdrawals and R2T4 calculations to ensure that correct dates and institutional charges are being used. Management's Response: Upon discovery of the errors, the University reviewed the population of withdrawn students where the dates for one module were used versus the payment period. The University performed the additional or revised Title IV calculations for five students and returned additional funds. The $10,819 reported as questioned costs identified by the auditors has also been returned. The university will also review 2022-23 award year of when the 49% exemption or one module in a payment period, and make any R2T4 corrections. Anticipated completion date is May 1, 2023 Contact Lori McDonald at lori.mcclonald@cui.eclu or 949-214-3074

November 17, 2022 To: Chair of the Audit Committee From: Debra Martin, Vice President for Finance and Administration RE: Response to Baker Tilly Audit Communication ? Uniform Guidance Audit Findings Finding 2022-004: Nursing Student Loans Program: Nursing Student Loans (NSL) Assistance Listing Number (ALN): 93.364 Federal Agency: U.S. Department of Education Federal Award Identification Number: Unknown Federal Award Year: June 30, 2022 Criteria: U.S. Department of Education regulations require for a NSL loan, repayment must begin nine months after the student ceases to be a full-time or half-time student, except as required in 42 CFR 57.310(a). For NSL loans after November 13, 1998, the 10 ?year repayment period may be extended for ten years for any student borrower who, during the repayment period failed to make consecutive payments and who, during the last 12 months of the repayment period, has made at least 12 consecutive payments. Institutions must exercise due care and diligence in the collection of loans. Many institutions engage third-party servicers for billing, collection, and processing deferment and cancellation requests, although these institutions remain responsible for compliance. Institutions are required to timely convert loans to repayment, establish repayment plans, process cancellation requests, and service loans as required. Condition: Seven of seven students who were tested had errors. The University had difficulty providing a listing of students who entered repayment on their NSL during fiscal year 2022. ? For one student, selected from an initial listing that ended up not being correct, the system screen showed the student separated from the University on May 8, 2020, however, the student was not noted as graduated for reporting to the NSLDS or provided with exit counseling to establish the repayment plan. ? Two students were noted as missing from the final listing provided and the servicer screen showed their status as `in school?, however they should have been indicated as `in repayment?. For one of these students, the exit counseling was provided but the student did not complete/sign it and the University did not follow-up to ensure it was completed or the repayment plan established. ? For three students that had separated from the University, the dates differed between system screens and servicer screens and exit counseling. One of these students was provided exit counseling but the student did not complete/sign it and the University did not follow-up to ensure it was completed or the repayment plan established. ? For one additional student, the exit counseling was provided but the student did not complete/sign it and the University did not follow-up to ensure it was completed or the repayment plan established. The sample was not a statistically valid sample as the auditors ended up testing the entire population. Cause: The University?s processes are not ensuring that information for NSL students is correct in the University or servicer systems, or that exit counseling is being performed or repayment plans established. Effect: Students with NSL are not being converted to repayment timely with established payment plans that can result in loans not being repaid. Questioned costs: Not applicable Context: Not applicable. Recommendation: It is recommended that the University review policies and procedures in place to resolve issues in a timely manner to facilitate compliance with NSL regulations. Management?s Response: The University agrees with the recommendation and will review system, reporting functionalities and business processes contributing to these errors and implement corrective measures. Correction Action: The University will dedicate a Student Accounts staff to manage the loan program by providing addition policy training on processes and technology training with the third party loan processor. Student Account Staff will perform timely reconciliations on all Federal nursing loan programs with the external loan servicer to ensure the student?s status is accurate. We will be exploring the possibility of reporting directly to the NLDS.